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Exemptions › Disqualification

Dechert LLP

Not Quite QPAMDEMONIUM: DOL Issues Final Changes to the QPAM Exemption

Dechert LLP on

On April 3, 2024, the Department of Labor (the “DOL”) issued its final amendment (“Final Amendment”) to Prohibited Transaction Class Exemption 84-14, commonly referred to as the “QPAM Exemption”. Generally, the QPAM...more

Dechert LLP

CFTC Finalizes New Requirement Applying Statutory Disqualification Prohibitions to CPOs Exempt under CFTC Regulation 4.13 – Exempt...

Dechert LLP on

CFTC Also Proposes Amendments to Help Non-U.S. CPOs and Extends its Uncleared Swap Margin Phase-In Schedule - During the period from late May 2020 through early June 2020, the Commodity Futures Trading Commission held...more

Foley Hoag LLP

SEC Adopts "Bad Actor" Disqualification for Rule 506 Private Placement Offerings

Foley Hoag LLP on

On July 10, 2013, the Securities and Exchange Commission voted unanimously to adopt a “bad actor” disqualification for Rule 506 private placement offerings under Regulation D. Rule 506(d) will prevent issuers from relying on...more

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